Which workplaces in Turkey must prepare an explosion protection document?

Every workplace in Türkiye that falls under Occupational Health and Safety Law No. 6331 and where an explosive atmosphere may form must have an explosion protection document (patlamadan korunma dokümanı, often abbreviated PKD). The duty comes from the 2013 regulation on explosive atmospheres at work; it has no threshold for company size, number of employees or hazard class, and the document must exist before work starts.

Short answer

• Legal basis: the Regulation on the Protection of Workers from the Hazards of Explosive Atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik), Official Gazette (Resmî Gazete) 30 April 2013, No. 28633, prepared in parallel with Directive 1999/92/EC.
• Who: workplaces within the scope of Law No. 6331 where an explosive atmosphere of gas, vapour, mist or dust may form, apart from a short list of excluded activities.
• When: prepared before work starts (Article 10(3)); reviewed and updated when the workplace, the work equipment or the work organisation undergoes a significant change, extension or modification.
• What: a written record showing the explosion risk has been assessed, the measures taken, the zoned places, where the minimum requirements apply, and that equipment is safe and compliant.
• Combined documents: the employer may combine it with the general risk assessment and other reports (Article 10(4)).

Which workplaces are in scope

The regulation applies to workplaces under Law No. 6331 "where there is a possibility of an explosive atmosphere forming". It defines an explosive atmosphere as a mixture with air, under atmospheric conditions, of flammable substances in the form of gas, vapour, mist or dust that can burn through completely when it meets an ignition source. Annex 1 adds a strict presumption: flammable substances are treated as able to form explosive atmospheres unless investigation shows that their mixtures with air cannot propagate an explosion on their own.

The Ministry of Labour and Social Security implementation guide lists typical sectors:

The guide stresses that the list is only an example. A small workshop with a solvent store, a bakery with a flour silo or a car body shop with a spray booth is in scope as much as a refinery. The regulation contains no condition on the workplace hazard class (tehlike sınıfı) or on the number of employees.

What is excluded

The regulation does not apply to: areas used for and during medical treatment of patients; use of appliances under the gas appliances regulation; manufacture, handling, use, storage and transport of explosives and chemically unstable substances; mineral extraction by drilling and surface or underground mining; and use of means of transport subject to international agreements (but transport means used inside a potentially explosive area remain covered). Activities outside Law No. 6331 itself, such as domestic services and people working on their own account without employees, are also outside.

What the explosion protection document must show and when

Article 10(2) lists the minimum written content:

1. that the explosion risks have been determined and assessed;
2. the measures taken to meet the regulation;
3. the places classified into zones according to Annex 1 (Zones 0, 1, 2 for gas, vapour and mist; Zones 20, 21, 22 for dust);
4. the places where the minimum requirements of Annexes 2 and 3 apply;
5. that workplaces and work equipment, including warning devices, are designed, operated, checked and maintained with due regard for safety;
6. that all equipment complies with the regulation on the use of work equipment (25 April 2013, No. 28628).

The guide adds that the document has no fixed format, and that the team preparing it may set its own review period in addition to the change-driven updates the regulation requires. Documents prepared under the earlier 2003 regulation (26 December 2003, No. 25328) remained valid under a transitional article.

Where a workplace has several employers, each is responsible for its own area, and in a main-employer and subcontractor relationship the main employer coordinates and writes the coordination arrangements into the document (Article 8). In business centres and industrial estates with many workplaces, the management coordinates and warns employers whose explosion hazards could affect others.

Who prepares the explosion protection document

The employer is responsible. The regulation does not name a profession or a certificate for the author; the PKD is part of the explosion risk assessment, which the general risk assessment regulation (29 December 2012, No. 28512) assigns to a team formed by the employer, including the employer or representative, the occupational safety specialist, the workplace physician, employee representatives, support staff and knowledgeable employees, with outside services allowed where needed. Annex 2 requires that, before work starts, the explosion safety of the whole workplace is verified by persons trained and/or experienced in explosion protection. In practice the zoning and equipment checks need someone with real Ex competence; see who can prepare an EPD in Turkey.

Common mistakes

• "Only very hazardous class workplaces need a PKD." The regulation has no hazard-class or size condition; the possibility of an explosive atmosphere decides.
• Writing it after start-up. It must exist before work starts.
• Filing it once. A new solvent, a new dryer, a new extraction system or a layout change requires review and update.
• A PKD without zone drawings. The classified places are part of the mandatory content.

Related on excodex

• The Explosion Protection Document (EPD) and area classification drawings under ATEX 1999/92/EC
• ATEX explained: the two EU directives 2014/34/EU and 1999/92/EC in plain language
• What is the Turkish equivalent of the ATEX directives?
• What is the Ex warning sign and where must it be placed?
• Standards space: Turkish explosive atmosphere regulations

Standards and further reading

• Regulation on the Protection of Workers from the Hazards of Explosive Atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik), Resmî Gazete 30.04.2013, No. 28633: resmigazete.gov.tr
• Ministry of Labour and Social Security, implementation guide on protecting workers from explosive atmospheres (2015, revised 2024, in Turkish): csgb.gov.tr
• Occupational Health and Safety Risk Assessment Regulation (İş Sağlığı ve Güvenliği Risk Değerlendirmesi Yönetmeliği), Resmî Gazete 29.12.2012, No. 28512: resmigazete.gov.tr
• Occupational Health and Safety Law No. 6331 (İş Sağlığı ve Güvenliği Kanunu), Resmî Gazete 30.06.2012: resmigazete.gov.tr
• Directive 1999/92/EC, the EU workplace directive the Turkish regulation follows.

This article is general technical information prepared by the excodex editorial team. It does not replace the applicable standards, the equipment certificates and instructions, national regulations or the assessment of a competent person.